This content is from: France Changes to OECD Transfer Pricing Guidelines approved The OECD has approved updates to the Transfer Pricing Guidelines in its first major revision since they were released in 1995. July 27 2010
This content is from: China SAT gives details of sample documentation review in China A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities. July 27 2010
This content is from: United States Congressional transfer pricing hearing affirms arm’s-length standard The House Ways and Means Committee’s hearing on transfer pricing issues revealed concern over US corporations’ ability to remain competitive internationally but did not disturb the general consensus around the arm’s-l... July 27 2010
This content is from: United Kingdom PricewaterhouseCoopers promotes transfer pricing director Yvonne Cypher joined the firm in 1997 and specialises in transfer pricing with a particular focus on business restructuring. July 27 2010
This content is from: Brazil Production cost-plus profit method has problems and benefits Cristiane Magalhães and Victoria Rozsavolgyi Bortolin of Machado Associados advise taxpayers in Brazil on when it is best to look for alternative methods to use when establishing transfer prices. July 26 2010
This content is from: United Kingdom HMRC to publish APA figures Her Majesty’s Revenue and Customs (HMRC) is to release figures relating to the negotiation of advance pricing agreements (APAs) and “other aspects of transfer pricing” imminently. July 26 2010
This content is from: India Mumbai tribunal accepts higher price paid to AE Hasnain Shroff and Vinita Chakrabarti report on the Mumbai Tribunal’s ruling in the case of M/s Cheminova India Limited where a higher price paid to associated enterprises was accepted as the arm’s-length price, due t... July 25 2010
This content is from: Taiwan Taiwanese taxpayer goes to court over transfer pricing A service provider has become one of the first companies to take a transfer pricing dispute to the Supreme Administrative Court. July 20 2010
This content is from: Greece Greece increases transfer pricing penalties As part of the overhaul of Greece’s tax system, transfer pricing rules have been strengthened, including raising the penalty for not submitting documentation to 20% of the amount of the transaction. July 20 2010
This content is from: United States JCT uses confidential taxpayer information in report A report on transfer pricing from the Joint Committee on Taxation (JCT) in the US has used private company information to outline case studies in a report which concluded that US rules are open to abuse. July 20 2010
This content is from: India Tribunal reinforces applicability of methods and rules on interest levy Hasnain Shroff, Vinita Chakrabarti and Akash Arora discuss the Nimbus Communications Ltd Vs ACIT, Mumbai (ITA No.2361 (Mum.) of 2007) case and its implications for transfer pricing. July 19 2010
This content is from: United States All change at KPMG Steven Tseng, China partner in charge and Asia Pacific leader for KPMG’s global transfer pricing services is moving to PricewaterhouseCoopers in China, at the same time as many new appointments are made in the US. July 15 2010
This content is from: Australia Australia to reform CFC rules Australia’s assistant treasurer has released for public comment a discussion paper that represents a further step towards reforming the country’s controlled foreign company (CFC) rules. July 15 2010
This content is from: Russia Russian companies prepare for new transfer pricing rules Companies adopt a wait and see attitude to Russia’s new transfer pricing rules. July 13 2010
This content is from: Transfer Pricing Mexico eases administrative burden on taxpayers On June 30 2010 a new decree was published in the Mexican Federal Official Journal, which grants new administrative relief to taxpayers. July 13 2010
This content is from: Czech Republic New partner for PricewaterhouseCoopers in the Czech Republic David Borkovec has been made a partner in the PricewaterhouseCoopers tax and legal services department in Prague. July 12 2010
This content is from: United Kingdom LECG adds transfer pricing expertise in Europe The acquisition by LECG, a global business advisory and professional services firm, of Bourne Business Consulting, a London firm, closed on July 2. July 12 2010
This content is from: Australia ATO compliance program hits transfer pricing hard The Australian government hopes to use international information exchange as part of an increased scrutiny of transfer pricing arrangements. July 12 2010
This content is from: India Indian case changes landscape for marketing intangibles The Delhi High Court has issued a landmark ruling providing guiding principles on the applicability of the arm’s-length standard to the realm of marketing intangibles. July 11 2010
This content is from: Norway Norwegian authorities win interest level in cash pooling system case Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies recei... July 11 2010
This content is from: Australia Car-maker Toyota settles A$246.7 million dispute in Australia The company reported making a loss of A$107.9 million ($94 million) after being hit with a tax adjustment reportedly relating to intercompany transactions. July 11 2010
This content is from: United States McClellan moves to General Electric Holly McClellan, a partner of Baker & McKenzie in Chicago, will join the corporate tax group at General Electric as transfer pricing leader, tax counsel, for treasury and capital markets on August 16. July 08 2010
This content is from: Sweden Retailer criticised for “immoral” tax practice Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 06 2010
This content is from: Transfer Pricing OECD must look at intangibles, urge specialists The OECD has announced it may begin a project to investigate the issues of transfer pricing involving intangible property, much to the approval of specialists in the field. July 06 2010
This content is from: European Union European business warms to CCCTB Taxpayers are looking into how a common corporate tax base might affect transfer pricing after a new report into how to complete the EU single market lent support to the plans of Algirdas Šemeta, European commissioner... July 05 2010
This content is from: China China makes transfer pricing a top priority The Chinese tax authorities have identified transfer pricing and anti-avoidance as their main priorities for 2010 and have begun to target to specific industries. July 05 2010
This content is from: France TP Doctor: New French transfer pricing documentation requirements Gianmarco Monsellato and Sylvain Chevrier of Taj, a member of Deloitte Touche Tohmatsu, answer commonly asked questions about the implementation of the new French documentation rules. July 05 2010
This content is from: United States IRS settles with Citrix Systems for $66 million less than expected Citrix Systems, a provider of IT solutions, has announced it has settled with the IRS in the range of $12 million to $15 million over disputes about transfer pricing and intellectual property transfers. July 05 2010
This content is from: Transfer Pricing Transfer pricing enters new age International Tax Review’s 10th annual Global Transfer Pricing Forum will be an opportunity for transfer pricing professionals from business, government and private practice to focus on the key issues in related-party... July 05 2010
This content is from: Indonesia Indonesian government asks for input on new guidelines The Indonesian directorate general for tax (DGT) has reinvigorated the campaign to crack down on transfer pricing abuse by meeting with advisers from different firms and asking for input before new guidelines are rele... July 04 2010
This content is from: Brazil Brazil enacts thin capitalisation rules The Brazilian Congress has passed thin capitalisation rules that will affect the deductibility of interest payments, among other things. July 04 2010
